Section 965 Liability definition

Section 965 Liability means the “net tax liability” of the Merck Group under Section 965(h)(6)(A) of the Code.
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Section 965 Liability means the amount representing the “net tax liability” of HII under Section 965(h)(6)(A) attributable to the SpinCo Business, as determined by HII. Promptly following the date of the Distribution, HII shall determine the amount of the Section 965 Liability and shall notify SpinCo of such amount of such determination no later than November 15, 2018. Thereafter, if as a result of any audit adjustment or otherwise, HII determines that the amount of the Section 965 Liability should be increased or decreased, subsequent payments under Section 3.02(g) shall be appropriately adjusted. Determinations of Section 965 Liability hereunder shall be made by HII in its sole discretion.
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Section 965 Liability means the amount representing the “net tax liability” of HII under Section 965(h)(6)(A) attributable to the SpinCo Business, as determined by HII. Promptly following the date of the Distribution, HII shall determine the amount of the Section 965 Liability and shall notify Spinco of such amount of such determination no later than November 15, 2018. Thereafter, if as a result of any audit adjustment or otherwise, HII determines that the amount of the Section 965 Liability should be increased or decreased, subsequent payments under Section 3.02(g) shall be appropriately adjusted. Determinations of Section 965 Liability hereunder shall be made by HII in its sole discretion.
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Examples of Section 965 Liability in a sentence

  • The amount of Section 965 Liability shall be converted into Euros on a U.S. dollar-to-Euro exchange rate determined by HII, in good faith, as of a date within two business days prior to the Distribution Date.

  • The amount of Section 965 Liability shall be converted into Euros on a U.S. dollar-to-Euro exchange rate of [•]1.

  • HAPI has entered into an agreement with HII pursuant to which HAPI has agreed to indemnify HII from and against such Section 965 Liability.